1)
By virtue of its location, design, height and materials the proposals would fail to preserve or enhance the character and appearance of the conservation area and would harm the setting of the adjacent grade II listed terrace, contrary to the statutory requirements for a conservation area and listed building, and the development plan in particular policies Local Plan policies CL1, CL2, CL3, CL4 and CL11. The less than substantial harm to the townscape, conservation area and setting of listed buildings would not be outweighed by sufficient public benefits.
2)
The proposed building by reason of its height and proximity to neighbouring buildings would result in an undue sense of enclosure to the rear windows and gardens of 180-184 (even) Holland Park Avenue and 42-44 Royal Crescent, and the southern end of Royal Crescent Mews, which would fail to have an acceptable impact on neighbouring living conditions, contrary to development plan policy, in particular Local Plan 2019 policy CL5.
3)
The proposal fails to demonstrate that the proposed building by reason of its height and location would not result in a material loss of light to the rear windows and gardens 42-44 Royal Crescent, and to the southern end of Royal Crescent Mews in particular no. 32. As such the proposals fail to demonstrate compliance with Local Plan 2019 policy CL5.
4)
The application fails to demonstrate that the proposals would not result in the damage or loss of trees of townscape or amenity value, contrary to development plan policy, in particular Local Plan policy CR6 and the Trees and Development SPD.
5)
The application fails to demonstrate that the long-term servicing of the site would not give rise to traffic congestion, conflict with pedestrians or be detrimental to residential amenity, contrary to development plan policy in particular Local Plan policy CR7.
6)
In the absence of an acceptable Construction Traffic Management Plan the application fails to demonstrate that the proposals would not result in unacceptable harm to pedestrian, cycle, vehicular and road safety, contrary to development plan policy, in particular Local Plan 2019 policy CT1 and the Transport and Streets SPD.